The All India
Civil Accounts Employees Association is very thankful to learn from your office
letter No. A.34012/On line/MF.CGA (E)/522 dated 20th June 2018 that
in response to its letter NO. AICAEA/HQ/A-2/2018/191 dated 26-05-2018 you have
kindly agreed to convenea meetingwith the representatives of the Association
exclusively on the matter of restructuringof AAO(Civil) Examination subject to the condition that the Association
sends its comments within 30th June 2018 .

Therefore,
on behalf the All India Civil Accounts Employees Association, I am forwarding
herewith our suggestions and comments in the enclosed Annexure “A” and Annexure
“B” respectively.In the Annexure A we have
suggested and commented against the modifications in the pattern of the
examination and in the annexure B we have done a brief analysis of Old
&New pattern of AAO (Civil) exam based on Syllabus.

The comments,
suggestion and analysis forwarded by this Association are on the basis of the
suggestions and proposals received from the Branches, Units and individual
members of the All India Civil Accounts Employees Association and All India
Civil Accounts Employees Association Category II spread throughout country. The
suggestions, proposals and analysis represent democratically composed views of
more than four thousand candidates and prospective candidates for AAO (Civil)
examination.

I have been
directed by the Association to request you that, the All India Civil Accounts
Employees Association being the sole monolithic employees organization
representing the examinees of the AAO (Civil) Examination, a formal meeting
with the National Executives of the Association may kindly be convened as per
earlier precedents and meetings of 1980 and 2006 in particular before
finalizing the new pattern and syllabus for the futureAAO (Civil) Examinations so that the
Association could offer its oral deposition in support of the comments,
suggestion and analysis it has forwarded.

Since the
suggestions, proposals and analysis from our field formations and members are
still flowing in to Association headquarters, we may send additional
suggestions/ proposals in continuation of the suggestions, comments and
analysis we have forwarded through this letter.

Thanking
you,

Yours
Sincerely,

Enclo as above

(V.
Bhattacharjee)

Secretary
General

ANNEXURE
“A”

Proposal
of CGAoffice

Comments/Suggestions of AICAEA and AICAEA CAT-II

2. (I) The examination will be conducted online through
outsourced agency.

Conducting the examination through
an outsourced agency would further increase the chances of malpractices and
an invitation of technological intervention. At present, in the exams
conducted by SSC, DSSSB etc. we have seen that conducting exams through an
outsourced agency is not at all secured and it becomes a bone of contention
to the commission. In present ambience of technology it is easier for the
hackers to provide the questions on the platform of social media.

The recently conducted Combined
Graduate Level Examination 2017 conducted by Staff Selection Commission
through online mode with outsourced agencies proved to be a disastrous one.
17 people including 10 employees of an outsourced agency have been found
guilty by CBI for leakage of question papers. The question has already been
raised how a fair examination can be conducted by an outsourced agency.

If the online mode of examination
becomes so warrant, the same may be conducted (in existing 8 paper patterns)
departmentally with the help of NIC and not by any outsourced agency.

2. (Ii) The Examination will be completely of objective
multiple choice questions.

Conducting all the exams on
completely objective multiple choice questions pattern is an initiative
towards ease the examination process and reducing the time frame. But, in
existing pattern of the examination each paper has 2 parts (35 marks
objective and 65 marks subjective).
In such pattern of
examination the objective knowledge as well as the practical knowledge and
writing skill of a candidate is wholly judged. He has to answer some
compulsory practical questions in each paper, which has a set pattern of
answer.

Hence,
making the exam completely objective will leave the candidates bereft of the
comprehensive view of the syllabus which is the foundation for the work
profile of an AAO.

2.(iii)The Examination will be comprised of 4 papers details
of which are at Annexure A & B

The concept of 8 Paper systems has been unchanged in
CA&G’s Organization even after switching over to Online Examination
system. Hence same may continue.

2.(iv)Each paper will have 100 objective multiple choice
questions for one mark each. There will be no negative marking.

As per the proposed pattern of the
examination, there would be only 4 papers comprising the whole old syllabus
with many new topics. While examining the new syllabus it has been noted that
Paper 3 has subsumed all the papers relating to accounting procedures viz.
(Paper 3, 6 & 8) with many new topics relates to electronic portals. It
has more than 20 books to be referred and shall make the candidate over
burdened. Current procedure is more
logical

In this
context, following points are suggested that there should be 8 papers instead
of 4 papers so that candidates can get sufficient time to prepare for the
papers.

i)The new topics may be added in the
relevant papers accordingly.

ii)In 8 papers, there is no need of
merging the syllabus, so that the candidates can easily go through the whole
syllabus.

iii)In 8 papers, there would be healthy
question bank to test the wisdom of the candidates.

2. (V) 65% will be of basic level, 25% will be of advance
level and 10% will be difficult.

Proposed pattern of 4 papers on
almost all subjects cannot give justice to fair practice in exam system and
difficulty level of questions cannot be ensured.

Current system is more logical.

2. (VI) Time allowed for each paper will be two hours.

In the proposed pattern time is
being allowed 2 hours for 100 multiple choice questions. In the existing
pattern there are 35 objective questions and time allowed to answer these
questions is 1 hour. Moreover, books are also allowed to answer the
questions.

It is
therefore, suggested to increase the time limit from 2 to 3 hours, so that
candidates have sufficient time to answer all the questions.

2. (Vii) The present examination with its open book system does
not appropriately test the skill of the candidates as copying from books is
not enough to pass the examination. Therefore no books will be allowed in any
of the 4 papers under the revised pattern.

In the existing pattern of the
examination, books are allowed in Papers 2 to 7 and the candidate has to
quote the rule positions while answering the questions Unfortunately, it has
been concluded that merely copying books is enough to pass AAO (C) Exam. It
is not too easy to answer all the questions from copying the referral books.
While answering the questions, candidates have to go through all the referral
books and it is not feasible for them to mug up the whole syllabus to answer
in objective manner. It is experienced that it is quite tough to clear the exam
by merely copying the books with a laymen’s knowledge about the subject and
without having sound knowledge/concept of the papers. In the last conducted
AAO (C) Exam (2017), only about 8% candidates (138 of 1823) have cleared the
examination. And it is about 4% candidates (69 of 1823) who have successfully
passed all the 08 papers in a single attempt which clearly shows that passing
AAO (C) Exam is not a copy work at all. There are hardly any candidates
available who have appeared in the examination without books and still
majority of the candidates have passed only 1 or 2 or 3 papers.

Hence, books may be allowed in
future examinations in revised pattern, as was done in previous years since
inception of this examination in this Organization.

2(viii) Minimum marks for pass in each paper is 50 for General
Category and 45 for SC/ST. A candidate who passes in all the four papers will
be declared as passed in the Examination.

Accepted but the no. of Papers should be 8 instead of proposed
4. Existing policy of granting promotion to the LDCs as Accountants on
passing 4 papers should continue and the facilities should be extended to the
candidates below the level of Accountant appearing the examination. MTS being
Gr.C, Graduate among them should be allowed to appear the AAO (Civil)
examination.

2.(ix)A candidate who fails to pass the Examination as a whole
in one attempt but secures a minimum of 50 or 45 marks, as the case may be,
in one attempt in any paper will be exempted for reappearingin that paper of the immediately succeeding
Examination. If the candidate fails to avail the opportunity and passed the
Examination as a whole in the said succeeding Examination, he/she will have
to reappear in all the 4 papers of the second succeeding Examination or any
other subsequent Examination.

Exemption by securing
50/45 marks in any paper may be treated as valid for ensuing years till
passing the remaining papers within consecutive six chances instead of valid
for only one immediate succeeding year.

It is proposed that for all candidates who have cleared few
papers upto AAO (C) Exam 2017 be given chance to clear remaining papers in
future attempts restricted to overall 6 attempts.

2.(x)Exemption secured upto and including the AAO (C)
Examination,2017 will not be valid underthe revised pattern.

This is really a traumatic proposal
for the candidates who had secured upto 7 exemptions in the previous exams.
The hard work and the expensive time which was spent for this examination
will go in vain.In the revised
pattern we have seen that almost all the syllabus is same except some new
topics. Hence, there is no need of making the exemptions invalid.

However, following points are suggested/raised in this regard:-

i)While in new pattern Instead of 4 papers
8 papers on new pattern, exemptions can continue without any problem

ii)In the existing pattern, candidates
who had passed 4 papers were promoted from LDC to Accountant, but this
revised pattern is silent over the criteria of promotion.

2.xi)A candidate will have get 6 chances to pass the
Examination.

Agreed. Whether old or new pattern, 6
consecutive/ continued chances to clear the 8 papers must be given to all.

2.(xii)There will be no requirement for passing the CCC
Examination conducted by NIELIT. Basic skills in computer operations can be
imparted during the Induction Training at INGAF.

Agreed.

2.(xiii)Eligibility to appear in the Examination will remain
the same except(i) the cutoff date
for determining the eligibility will be the first day of month in which
Examination is held as against 1st October of the year of
Examination under the existing pattern and (ii) the prospective candidates
should have successfully completed the period of probation in the existing
grade.

Agreed.

2.(xiv)All successful candidates will have to undergo
mandatory Induction Training for not less than 4 weeks inINGAF after qualifying the AAO( C)
Examination and getting promoted as AAO. The training is followed by a test.

Agreed with the following slight modification.

The proposed provision of ‘Test’ after completion of Induction
Training on passing AAO (C) Examination may be done away with.

Finally the following new proposals are
submitted for the sake of new dynamic and energetic examinees of this
organization.

1.Sample question papers for all the 8 papers of the new syllabus
along with training video of various procedures to be done in on line
examination may be available in the website cga.nic.in for habituating with the
new concept adopted first time in this organization.

2.Study Materials as far as possible at least the Govt.
Publications may be made available in the website cga.nic.in well in advance.

3.The candidates may be provided sufficient time for preparation
after finalization and notification of the revised examination procedure as it
is to be introduced first time in this organization.

4.Scope of proper training facility may be provided for the
candidates, appearing first time in this examination, in INGAF or any other
suitable Training Institutes in Government cost.

ANNEXURE “B”

BRIEF ANALYSIS OF OLD
&NEW PATTERN OF AAO (CIVIL) EXAM BASED ON SYLLABUS

As per proposed syllabus, neither
subjective papers nor language paper is there, in this circumstance, it would
not be possible to judge whether the prospective AAO will be skillful as AAO
post is of supervisory nature which needs acute knowledge in noting and
drafting.Academicians are of the
opinion that language is the best tool to judge the very personality of human
being. The practical / subjective kind of paper is a must to perform the nature
of duty of AAO in well manner. How can any one measure efficiency of AAO
without checking any practical papers.

How is this possible for an official
to memorize all the rules thoroughly including all the correction slips which
are revised / amended from time to time. Furthermore, all these rules are
scattered in about 55 numbers of books. So, it is not feasible for the
aspirants to learn by heart all the rules accurately contained in all books
stated above. These apart, being in Accounts office AAO does scrutiny /
referential kind of work, which requires concerned reference rule books along
with its applicability. Hence it is essential that exam should be conducted
with books instead of without books.

As per new pattern, timings of paper
in exam is 2 hours each for four papers (8 hours as a whole). If talking about
the old pattern timings of paper was 3 hours each for 8 papers (24 hours as a
whole) along with the allowed books. Timing dedicated in new pattern is 1/3rd
times when compared to old pattern. The percentage of successful candidates is
around 7.6 % in old pattern with books. Keeping the time frame in view as per
proposed exam pattern, it may be deduced that the percentage of success will
become 2.5 % approximately with respect to time provided as a whole in the new
pattern, if without books is taken into consideration then this success ratio
will tend to zero. Henceforth as per above clarification we may assume that the
proposed new syllabus will be fruitful neither for the organization nor for the
candidates.

Moreover, it is also not feasible for
the office of CGA to cover whole syllabus of 9 papers (including CCC) in just
four papers. If it is made possible, then it cannot be ensured that the
candidates who will clear AAO (civil) examination will have desired knowledge.

The description for the contents of
paper wise syllabus is detailed in Table-A and Table-B below.

Knowledge of Audit manual, GeM,
NTRP, latest technologies used in different ministries and syllabus content
of each book

2 months

Paper
8

Books
not allowed

Completely Practical and numerical
based

Minimum 4 numerical question based
compulsory

Knowledge of basic principles of
accounting, Management Accounts etc.

6 months

*
The syllabus of paper-7 was revised in a very short notice and was given
meager time to prepare for AAO Exam 2017.

In view of the above table B, it can
be inferred that total months required to compete the examination is more than
a year, so exemption of previous papers required.

As per the old syllabus of AAO exam
(upto 2017), there were 8 (eight) papers and 1 (one) paper i.e., CCC (Course on
Computer Concept) need to qualify by the candidates to pass AAO (civil)
examination.

With reference to the OM regarding
Restructuring of AAO (Civil) Examination issued by O/o CGA, the new syllabus
has been proposed. According to which there will be 4 papers only. But, when we
go through the content of the syllabus designed for all 4 papers, we will find
that all 9 papers (including CCC) are combined haphazardly in just 4 papers.
This seems impractical to study and the same is already explained above in
tabular format.

After doing a comparable study and
detailed scrutiny of both syllabus and pattern, detailed analysis and comments
on new patterns is discussed below keeping new syllabus papers into
consideration and as a base for detailing:

1.Paper-I
of New Pattern-It is noticed that contents of Paper-I of new pattern comprises
of Paper-2, Paper-5 & Paper-1 of old pattern. Now talking about the old
pattern Paper-2 is related to Service Rules, minimum number of books used while
studying in paper-2 is 16 (including practice set, hand book and objective
guide). As this is basic working of Civil Accounts Organization. The officials
need to have a practical knowledge along with the knowledge of prescribed forms
and formats used in day to day working of office. Officials should be aware
about the rules and its applicability involved in these forms. In view of this,
there is a requirement of vast knowledge and effort by an individual to master
in it.

If talking about the paper-5 of old
syllabus, through this is a theory paper, it deals withthe disciplinary proceedings involved if any
misconduct been performed by any official, it also deals about the procedure to
be followed in an office for its smooth functioning and increases also office’s
productivity. One new topic is introduced in paper-I of new syllabus which is
e-office, which is again a vast and of large domain, it alone requires well
knowledge of paper-2 and paper-5 of old syllabus which will become very tough
for the individual to memorize all rules and apply it wherever needed.

Moreover, this paper also
includes whole syllabus of paper-1 of old syllabus i.e., the knowledge of
grammar and comprehension, which is again becoming extra over head to the
examinee along with paper-2 & paper-5 of old pattern. It is recommended
that there should be two separate papers keeping in view of such a large
syllabus involved in this paper.

2.Paper-II
of New Pattern-In this paper after doing comparative study of both old pattern
and new pattern, it came to notice that this paper comprises paper-3, paper-4,
paper-5 & CCC (whole syllabus) of old pattern.

Talking
about the practical papers paper-3 of old pattern, which requires knowledge of
preparation of appropriation accounts and CAM-33 which is alone a tough task
for the candidates not only need to memorize major heads including sub-heads
but also need to remember the procedure and proper methodology to solve
appropriation and CAM-33 problems. It requires a lot of practice.

CCC
(Course of Computer Concepts), this paper alone requires working knowledge of
computer along with proper terminologies involved in it. This is again a vast
area.

Some
part of paper-4 of old pattern like principles of budgeting, DFPR is taken into
this paper.

CBDT
Manual and CBEC Manual which are specific to some ministries were a part of
paer-5 in old pattern. In this scenario, candidates working other than these
ministries need to memorize without any practical acquaintance which is again a
tough task.

Talking
about the volume of paper-II in new pattern, it is again very hard for any one
to memorize and perform in this paper. It is recommended that there should be
two separate papers keeping in view of such a large syllabus involved in this
paper.

3.Paper-III of new pattern- In this
paper, paper-3, paper-5, paper-6 (complete syllabus), paper-7, paper-8
(complete syllabus) of old pattern are included.

Paper-6 and paper-8 of old pattern
arepractical papers, which require
numerical approach to be clear.Paper-6 is specific to Public Works Department
and very few group B and C non-Gazetted officials get the opportunity of
exposure to this kind of official work. So, it requires lot of efforts to go
through the problem been asked in examinations especially practical questions
and requires a lot of practice to meet the accuracy upto some extent to be
successful in exam.

Paper-8 of old
pattern is also a practical paper and is without books. This paper deals with
the accounts subject usually use to study in academic classes of XIth and XIIth
std. This paper alone requires 6 months of rigorous study to ensure passing in
this paper.

Out of these 4
papers introduced in new pattern. Paper-III of new pattern is the vast one.
There should be at least three separate papers based on the syllabus involved
in this paper.

4.Paper-IV
of new pattern- This paper included paper-4 and paper7 of old pattern. Both
papers are of theory nature. It also includes new topics like eRAS, APMS which
is not in old pattern. Thus, it makes again an extra burden to the candidates.

Conclusion:
As per detailed stated above It can be inferred that there should be 8 papers
with books allowed in place of 4 papers without books for AAO (Civil) Exam.